ARTICLE · 03 JULY 2025

Updated Standard Form 328, "Certificate Pertaining To Foreign Interests"

Goodwin Procter LLP

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On May 12, 2025, the Defense Counterintelligence and Security Agency (DCSA) released an updated Standard Form 328 (SF-328), "Certificate Pertaining to Foreign Interests."

United StatesGovernment, Public Sector

Jessica Aldrich

Alexander Vivona

Bottom Line Up Front

On May 12, 2025, the Defense Counterintelligence and Security Agency (DCSA) released an updated Standard Form 328 (SF-328), "Certificate Pertaining to Foreign Interests." The new SF-328 includes a number of changes to existing questions, as well as expanded instructions that are designed to assist filers in complying with the more detailed disclosure requirements imposed by SF-328. The National Industrial Security System has adopted the updated SF-328; accordingly, all companies filing facility security clearance (FCL) applications or changed condition packages after May 12, 2025, are now required to use the updated SF-328. The updated SF-328 has also been authorized for use by the federal government in connection with additional programs, which signals the Trump administration's focus on obtaining information about foreign interests in companies that do business — even unclassified business — as federal contractors or grant recipients.

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